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Patrickson v. Dole Food Co.
United States Court of Appeals for the Ninth Circuit
251 F.3d 795 (2001)
Banana-farm workers from Costa Rica, Guatemala, Ecuador, and Panama (the workers) (plaintiffs) brought a class-action suit in Hawaii state court against numerous global fruit and chemical companies (the companies). The case involved Hawaii common-law claims related to exposure to toxic pesticides in the workers’ home countries and raised no federal-law claims. The workers’ complaint did not allege any violations of federal rights or cite any acts done by foreign governments directly or through the companies acting under color of foreign law. The companies removed the case to federal court based on federal-question jurisdiction. The workers moved to remand the case back to state court. The district court denied the motion to remand and dismissed the case for forum non conveniens. The workers appealed. The companies argued that the federal common law of foreign relations was implicated in the case, so that federal-question jurisdiction was established. The companies argued that the ultimate resolution of the case could cause international tension by significantly affecting the banana industry in countries where the banana trade was an essential part of the economy.
Rule of Law
Holding and Reasoning (Kozinski, J.)
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